On October 6, 2014, the U.S. Supreme Court issued an order declining to review an appeals court’s broad interpretation of the Foreign Corrupt Practices Act (FCPA), a federal law that bans payments to a “foreign official” for the purpose of obtaining business. The decision was a setback for WLF, which filed a brief urging review. WLF argued that the term “foreign official” generally does not include employees of overseas commercial entities. The Petitioners are two American telephone executives who received lengthy prison terms for making payments to employees of Haiti Teleco, the telephone company in Haiti. The court held that the employees were “foreign officials” because—at the time of the payments—the government of Haiti owned a majority of Haiti Teleco’s stock. WLF argued that the FCPA does not apply to employees of commercial entities that do not perform traditional government functions, regardless whether a foreign government controlled the entity at the time of the payments.